https://www.taxtmi.com/caselaws?id=65571 Design, engineering, supervision and training services under an integrated technical contract were treated as fees for technical services rather than as a capital asset or plant, and the fact that drawings and designs were delivered in packed form did not change that character. Because the Indian permanent establishment was only supervisory and the core design work was performed in Germany, only a limited portion of the receipts was attributable to the permanent establishment in India, with attribution restricted to 10% of the receipts. Training of personnel in India was also held taxable as technical services. The operative principle was that, where technical services are rendered substantially outside India, only profits reasonably attributable to the Indian permanent establishment are taxable in India. en-us Tue, 08 Jul 2008 00:00:00 +0530 Tue, 07 Aug 2012 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65571 Design, engineering, supervision and training services under an integrated technical contract were treated as fees for technical services rather than as a capital asset or plant, and the fact that drawings and designs were delivered in packed form did not change that character. Because the Indian permanent establishment was only supervisory and the core design work was performed in Germany, only a limited portion of the receipts was attributable to the permanent establishment in India, with attribution restricted to 10% of the receipts. Training of personnel in India was also held taxable as technical services. The operative principle was that, where technical services are rendered substantially outside India, only profits reasonably attributable to the Indian permanent establishment are taxable in India. Case-Laws Income Tax Tue, 08 Jul 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65571